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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

REPUBLIC AIRLINE INC.

for an exemption pursuant to 49 U.S.C. § 40109

(United States-Dominican Republic)

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Docket DOT-OST-2014-______

APPLICATION OF REPUBLIC AIRLINE INC.

FOR EXEMPTION AUTHORITY

Communications with respect to this document should be addressed to:

Ethan J. Blank

Vice President and General Counsel

Scott L. Durgin

Vice President, Administration

REPUBLIC AIRWAYS HOLDINGS INC.

8909 Purdue Road

Indianapolis, Indiana 46268

Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

+1 202 637 4999/5659

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

Counsel for

REPUBLIC AIRLINE INC.

October 24, 2014
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BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Application of

REPUBLIC AIRLINE INC.

for an exemption pursuant to 49 U.S.C. § 40109

(United States-Dominican Republic)

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Docket DOT-OST-2014-_____

October 24, 2014

APPLICATION OF REPUBLIC AIRLINE INC.

FOR EXEMPTION AUTHORITY

Pursuant to 49 U.S.C. § 40109 and Subpart C of the Department’s Rules

of Practice, Republic Airline Inc. (“Republic”) hereby applies for a designation

and an exemption authorizing it to provide scheduled foreign air transportation of

persons, property, and mail between a point or points in the United States and a

point or points in the Dominican Republic. Republic requests that its exemption

authority be granted as soon as possible and remain in effect for a period of at

least two years, or until 90 days after the Department’s final determination on a

Republic application for U.S.–Dominican Republic certificate authority,1

whichever occurs earlier.

In support of its Application, Republic states as follows:

1

See Application dated December 12, 2007, in Docket DOT-OST-2007-0084. In DOT

Order 2008-4-26 granting certain carriers, including Republic, broad U.S.–Open Skies authority,

the Department deferred its consideration of the request for U.S.–Dominican Republic certificate

authority, among others, because that proceeding only dealt with authority to serve Open Skies

partners. Id. at n.3.
Application of Republic Airline Inc.

Page 2

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1. Republic is a U.S. airline providing scheduled interstate air

transportation pursuant to a Certificate of Public Convenience and Necessity

issued by DOT Order 2009-9-13. Republic also has Open Skies certificate

authority and various exemption authorities for scheduled foreign air

transportation. See DOT Order 2008-4-26 (Route 882); Notice of Action Taken,

dated December 27, 2013 (Docket DOT-OST-2012-0026) (U.S.–Turks and

Caicos Islands); Notice of Action Taken, dated December 10, 2012 (Docket

DOT-OST-2011-0018) (U.S.–Bahamas).

2. Republic plans to begin daily nonstop “American Eagle” service

under the AA* designator code of American Airlines, Inc. (“American”) between

Miami, Florida (MIA) and La Romana International Airport, Dominican Republic

(LRM) with 76-seat EMB 175 aircraft in June 2015.2

3. Approval of this Application is in the public interest. Republic’s

proposed service will provide U.S. communities and travelers with enhanced

options for service to the Dominican Republic. The Miami–La Romana flight in

particular will benefit travelers not only in the Miami metropolitan area, but also

throughout the United States given the extensive connecting opportunities at

American’s major Miami hub.

2

American is already authorized to provide U.S.-Dominican Republic service. See

Certificate of Public Convenience and Necessity for Route 137, as issued by DOT Order 1996-5-9.
Application of Republic Airline Inc.

Page 3

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4. Although its initial service is planned for Miami–La Romana,

Republic seeks a broader exemption for U.S.–Dominican Republic authority so

that it has the flexibility to introduce additional U.S.-Dominican Republic services

in the future as market conditions and passenger demand warrant.

5. Republic is fit, willing, and able to perform the proposed U.S.-

Dominican Republic services. As noted above, Republic has authority to operate

scheduled interstate and foreign air service, including overwater routes between

the United States and points in the Caribbean. Its proposed services to the

Dominican Republic are not materially different in terms of aircraft size or stage

length from its previously authorized interstate and foreign air services.

6. Republic requests that the Department take official notice, pursuant

to Rule 24 of the Department’s Rules of Practice, of all other data on file with the

Department necessary to establish its fitness.

7. Approval of the requested exemption is consistent with the U.S.-

Dominican Republic air transport agreement, the overall state of aviation

relations between the two countries, and the broad U.S.-Dominican Republic

exemption authority previously granted to other U.S. carriers. See, e.g.,

ExpressJet Airlines, Inc., Notice of Action Taken, dated April 25, 2013 (Docket

DOT-OST-2006-24591); US Airways, Inc., Notice of Action Taken, dated

October 7, 2014 (Docket DOT-OST-2000-7340).
Application of Republic Airline Inc.

Page 4

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8. The Dominican Republic services proposed in this Application are

not projected to utilize more than 10 million gallons of fuel annually, and, in any

event, Republic does not envision having any difficulties in acquiring fuel for this

service.

WHEREFORE, for the foregoing reasons, Republic respectfully requests

that the Department promptly grant a designation and the requested exemption

authorizing it to engage in scheduled foreign air transportation of persons,

property, and mail between a point or points in the United States and a point or

points in the Dominican Republic, as described herein.

Respectfully submitted,

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Robert E. Cohn

Patrick R. Rizzi

HOGAN LOVELLS US LLP

Columbia Square

555 Thirteenth Street, NW

Washington, DC 20004

Counsel for

REPUBLIC AIRLINE INC.
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CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Application of Republic Airline Inc.

for an Exemption has been served this 24th day of October, 2014, upon each of the

following addressees:

robert.wirick@aa.com; howard.kass@aa.com; sascha.vanderbellen@delta.com;

chris.walker@delta.com; matwood@cozen.com; stephen.lachter@lachterlaw.com;

jhill@cooley.com; perkmann@cooley.com; bob.kneisley@wnco.com;

leslie.abbott@wnco.com; jyoung@yklaw.com; dkirstein@yklaw.com;

thomas.ting@suncountry.com; dan.weiss@united.com;

steve.morrissey@united.com;JCanny@amerijet.com;

jrichardson@johnlrichardson.com; brett.kruger@dot.gov; englets@state.gov;

info@airlineinfo.com

Jonathan Echmalian